Custis v. United States

Summary

The Court, in an opinion authored by Chief Justice Rehnquist and joined by Justices O'Connor, Scalia, Kennedy, Thomas and Ginsburg, held that 18 U.S.C. § 924(e) does not give a defendant the right to collaterally attack prior state convictions used for sentence enhancement, except where the conviction was obtained in violation of the right to appointed counsel. The Court relied on the statutory text, the absence of congressional authorization, and principles of finality and administrative convenience. Justice Souter, joined by Justices Blackmun and Stevens, dissented, arguing that the ACCA should be read to permit such challenges and that the Court’s reliance on negative implication and jurisdictional theory was misplaced.